In Farrell v. Tri-County Metropolitan Transportation District of Oregon, the Ninth Circuit Court of Appeals explained that Congress did not intend the FMLA to allow the recovery of emotional distress or punitive damages. However, the court affirmed a jury verdict of $1110 to cover plaintiff's lost wages for days of work missed because of the employer's FMLA violation. Plaintiff Farrell convinced the jury that denial of his request for FMLA leave caused him to miss several days of work because of the "stress" resulting from the wrongful denial of FMLA leave.